Strycker's Bay Neighborhood Council, Inc. v. Karlen 444 U.S. 223 (1980)
The US Department of Housing and Urban Development (HUD)
approved a project to build low-income housing in Manhattan. A local
citizen group, Stryker's Bay, opposed the project and sued.
Stryker's Bay argued that HUD had not properly considered
environmental impacts of the project as they were required to under the
National Environmental Policy Act (NEPA).
The Trial Court found for HUD. Stryker's Bay appealed.
The Trial Court found that HUD's decision-making process
was adequate.
The Appellate Court reversed and remanded back to HUD.
The Appellate Court found that NEPA required
consideration of alternatives to the project.
HUD prepared a lengthy report asserting that they had
considered all of the relevant factors and still found that the project
was not unacceptable. Stryker's Bay sued again.
The main reason HUD found the project to be acceptable
was that relocating the project would result in "unacceptable
delay."
The Trial Court found for HUD. Stryker's Bay appealed.
The Trial Court found that HUD had properly and in good
faith considered the alternatives and environmental impacts of the
project, thereby meeting their requirements under NEPA.
The Appellate Court reversed. HUD appealed.
The Appellate Court found that "unacceptable
delay" was a capricious reason for finding the project acceptable.
Instead, the Appellate Court suggested that HUD actually consider
environmental factors.
The US Supreme Court reversed the Appellate Court and
found HUDs assessment to be acceptable.
The US Supreme Court found that NEPA requires
"a fully informed and well-considered decision" but not
necessarily "a decision the judges of the Appellate Court would have
reached had they been members of the decision-making process."
Basically, as long as the agency considers the
environmental consequences of the project, NEPA is satisfied.
There are no specific rules on how an agency should weigh the factors
influencing their decision.
In a dissent it was argued that the Court has a role in
determining whether the decision was "arbitrary or capricious,"
and if so, they had a responsibility to overturn it.
What if after considering the environmental impacts, an
agency decided to permit a project solely because they thought the people
who opposed it were all dirty hippies? Would the Court feel they were
empowered to overturn the decision?